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#1 saucy

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Posted 23 October 2014 - 12:06 AM

As I'm sure you know, it can be very difficult to get definitive documentation from ingredient suppliers to show non-GMO status of ingredients that are considered at risk for genetic modification. However, a customer we manufacture for is using a well-documented, identity-preserved non-GMO corn starch. We are doing proper segregation & basically allergen-type procedures to minimize risk of cross-contamination.

 

The customer wants to list it as such on the label. I assume in the ingredients list, not as a label claim. But at this time I'm not sure which.

 

FDA issued guidelines in 1992 & 2001 but as understand has no specific regulations in place. I don't see in the guidelines where stating "non-GMO corn starch" on a label would be unacceptable, except that it would be preferable to state "This sauce is made with corn starch from corn that was not genetically engineered."

 

http://www.fda.gov/f...n/ucm059098.htm

 

I am interested in your opinion. Any input appreciated.

 

martib


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#2 fgjuadi

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Posted 23 October 2014 - 01:38 AM

As I'm sure you know, it can be very difficult to get definitive documentation from ingredient suppliers to show non-GMO status of ingredients that are considered at risk for genetic modification. However, a customer we manufacture for is using a well-documented, identity-preserved non-GMO corn starch. We are doing proper segregation & basically allergen-type procedures to minimize risk of cross-contamination.

 

The customer wants to list it as such on the label. I assume in the ingredients list, not as a label claim. But at this time I'm not sure which.

 

FDA issued guidelines in 1992 & 2001 but as understand has no specific regulations in place. I don't see in the guidelines where stating "non-GMO corn starch" on a label would be unacceptable, except that it would be preferable to state "This sauce is made with corn starch from corn that was not genetically engineered."

 

http://www.fda.gov/f...n/ucm059098.htm

 

I am interested in your opinion. Any input appreciated.

 

martib

You totally *could* put non-GMO on a label - we have a customer that requests this on the wrap.  There's no law against it, but it dilutes the language.  Think about "natural".  Think about "Artisan".  Don't turn "non-GMO" into the new "Natural". 

 

In addition, there are a ton of legislative battles happening, state by state.  The FDA/science maintains that GMOs have no health risk, but the public is very concerned about GMOs.  So labelling laws can go either way - and your stacks of "non-GMO", while totally fine now, might need to be updated frequently.  And we all know how expensive and awful changing packaging can be. 

 

 What is really better than doing that is getting the product Non-GMO Project certified.  Marketing will love this; purchasing, not so much.  With Quality and Organic and Kosher, you can really pick your standard from a range, but since non-GMO is so new, the Non-GMO Project is really the only reputable standard out there in the states.     There are some other standards like GMO Guard or CB specific certs,  but they're not widely recognized like the Non-GMO project.  I think the UK has Cert ID or something.


Edited by magenta_majors, 23 October 2014 - 01:40 AM.

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#3 saucy

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Posted 23 October 2014 - 02:27 AM

Magenta

Thanks for your reply. Customer is having ingredients evaluated by the non-GMO project as we speak and is assuming this one will be verified. All I have done to date is to state we'll wait for verification, then decide the terminology--if any--we can approve.

 

Boy howdy, are you ever right about the ton of lawsuits! "Natural" is very litigious lately, resulting in lawsuits and settlements.... lawyers are even contending that genetic modification in itself falsifies an all-natural claim. I guess the fact that I was not born in a cave and swaddled in hide of some sort means I'm not natural either... 

 

I'm probably not. I'm in QA. I don't live in the real world!

martib

 

 

 


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#4 Lisa_MG

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Posted 16 January 2015 - 03:39 AM

IME, we have been advised against adding non-GMo in the ingredient deck. 

 

As it was explained to me, the term "Non-GMO" is more of romance copy rather than a legal statement of identity.  Especially with Non-GMO not falling under any government regulations.  I was told that currently non-gmo is a "preference or lifestyle choice" until there are regulations in place by a government agency.

 

In that same regard, we are allowed to list the term Organic in our ingredient deck as our certification falls under USDA.

 

On the flipside, with all of that being said, when we submit our products to Non-GMO project for certification we have never actually listed the term Non-GMO in the ingredient deck to get feedback from them.  This is definitely something i will be inquiring about.  However, i also need to question their expertise in labeling before i allow them to guide me in listing something that can be a potential problem.


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#5 Lisa_MG

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Posted 16 January 2015 - 03:51 AM


Just to clarify, i was referring to what our facility was advised on in regards to labeling regulations
 
  "Especially with Non-GMO not falling under any government regulations.  I was told that currently non-gmo is a "preference or lifestyle choice" until there are regulations in place by a government agency."

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#6 christyh

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Posted 16 January 2015 - 06:37 PM

We are doing proper segregation & basically allergen-type procedures to minimize risk of cross-contamination.

 

martib

Hi martib,

 

My customer is in the process of getting their products certified with the non-GMO Project and they have asked us to provide SOPs that relate to our segregation of non-GMO items.

 

I see that you have done this.  Can you give me any hints as to how you have done this?  We already segregate for allergens and organics.

 

I am guessing that I need to compile a list of GMO and non-GMO items that come to our facility and segregate at the dock.  That will be a huge undertaking.

What do you do for a product that is non-GMO from one supplier and GMO from another?

 

Do you also segregate all the way through your processing?

 

Thank you for any help you can provide.

 

Christy


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#7 Snookie

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Posted 16 January 2015 - 08:01 PM

:welcome:  Christyh 


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#8 fgjuadi

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Posted 16 January 2015 - 08:28 PM

 

On the flipside, with all of that being said, when we submit our products to Non-GMO project for certification we have never actually listed the term Non-GMO in the ingredient deck to get feedback from them.  This is definitely something i will be inquiring about.  However, i also need to question their expertise in labeling before i allow them to guide me in listing something that can be a potential problem.

 

Ah, according to 3.2.4.Labeling, "Examples of claims that are not acceptable are“contains zero GMOs,” “GMO-free” and GE-free."  I think they prefer only using their seal?  You submit your labels to them to for approval (to ensure the seal matches their standards and there aren't any false claims), so you'll def get a review with their label expert.

 

 

Hi martib,

 

My customer is in the process of getting their products certified with the non-GMO Project and they have asked us to provide SOPs that relate to our segregation of non-GMO items.

 

I see that you have done this.  Can you give me any hints as to how you have done this?  We already segregate for allergens and organics.

 

I am guessing that I need to compile a list of GMO and non-GMO items that come to our facility and segregate at the dock.  That will be a huge undertaking.

What do you do for a product that is non-GMO from one supplier and GMO from another?

 

Do you also segregate all the way through your processing?

 

Thank you for any help you can provide.

 

Christy

I know this wasn't directed at me, but I'm gonna answer anyway, because.   Still would love to hear how others are doing these things as well.

 

I separate using my IP program (same for kosher).  We separate all the way through the process - when a *designated* non-GMO ingredient is delivered, we receive it in as we would an allergen (segregate, put in non-GMO storage, this does indeed happen at the dock).  We have hundreds of ingredients, and the vast majority do not contain GMO (chocolate, spices, salts, etc).  But we only store ingredients registered with the Project in our non-GMO storage. 

 

We originally were going to have two versions of ingredients (non-GMO for the registered products and GMO for the others), but the amount we need is roughly half a minimum order.  Since we must order over regardless, it ended up being less costly to buy the min order and use it for both products.


Edited by magenta_majors, 16 January 2015 - 08:29 PM.

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#9 saucy

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Posted 16 January 2015 - 09:50 PM

Regarding stating Non-GMO in the ingredient deck: From FDA guidelines 1992 & 2001:

 

"FDA reminds manufacturers that the optional terms that describe an ingredient of a multi-ingredient food as bioengineered should not be used in the ingredient list of the multi-ingredient food. Section 403(i)(2) of the act requires each ingredient to be declared in the ingredient statement by its common or usual name. Thus, any terms not part of the name of the ingredient are not permitted in the ingredient statement. In addition, 21 CFR 101.2(e) requires that the ingredient list and certain other mandatory information appear in one place without other intervening material. FDA has long interpreted any optional description of ingredients in the ingredient statement to be intervening material that violates this regulation."

 

Reference to:

 

CFR 21

§ 101.2 Information panel of package form food.

(e) All information appearing on the information panel pursuant to this section shall appear in one place without other intervening material.


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